Ycong v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners Felicitas Ycong and Teresa Polan obtained a loan of ₱125,000 from respondent Moller Lending Investor, executing a promissory note with a maturity date of 30 September 1994. Respondent alleged that petitioners received ₱105,000 after deducting ₱20,000 for 8% monthly interest for the first three months. Petitioners agreed to pay the loan in installments of ₱600 daily for 60 days, with 12% monthly interest on the outstanding balance after maturity. Petitioners made partial payments but failed to settle the outstanding balance. Procedural History: Respondent filed a complaint for sum of money and damages. The Regional Trial Court (RTC) dismissed the complaint, ruling that the 28 July 1994 promissory note did not involve a new loan, that petitioners did not receive ₱125,000, and that the note was signed under intimidation and coercion. The RTC concluded that petitioners had fully paid the last loan granted to Ycong. The Court of Appeals (CA) reversed the RTC decision, holding that the promissory note was the basis of the action, petitioners admitted the obligation through partial payments, and rejecting the claim of duress and intimidation. The CA ordered petitioners to pay ₱77,000 with 12% interest per annum from 1 October 1994. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, assailing the CA's decision and resolution, alleging grave abuse of discretion amounting to lack or excess of jurisdiction in reversing the factual findings of the RTC.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in reversing the factual findings of the trial court. Whether the promissory note dated 28 July 1994 was executed under duress and intimidation. Whether the petitioners had fully paid their outstanding loan obligations.
Ruling
The Supreme Court dismissed the petition, affirming the decision of the Court of Appeals. The Court held that a petition for certiorari is not the proper remedy to question errors of judgment and that the evidence on record supports the factual findings of the Court of Appeals.
Ratio Decidendi
On the Proper Remedy and Factual Findings of the Court of Appeals: The Court reiterated that a petition for certiorari under Rule 65 is available only when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. It is not a substitute for an appeal, which is the proper remedy for errors of judgment. The petitioners' claim that the appellate court erred in reversing the trial court's factual findings constitutes an error of judgment, not an error of jurisdiction. Therefore, certiorari is not the proper remedy. The Court found that the evidence on record supports the factual findings of the Court of Appeals. The promissory note itself, which states that petitioners promise to pay Moller Lending Investor the sum of ₱125,000 for a loan received, is the best evidence of the loan's existence. The Court rejected the petitioners' claim that Ycong did not receive the amount, noting that even if the note was an 'update' of a previous loan, the practice was to deduct the outstanding balance and release the remainder. Furthermore, petitioners admitted in their answer that they owe a balance, though they disputed the exact amount, indicating an acknowledgment of the loan's existence. The cross-examination of the respondent's proprietress also indicated that the actual amount received was ₱105,000 after deducting interest, disproving the claim of no receipt of funds. On Intimidation: The Court found Ycong's testimony regarding intimidation to be incredible. Her testimony was uncorroborated, as Polan, who was allegedly present, did not testify. Despite allegedly being threatened, neither Ycong nor Polan reported the incident to the police or sought help. Moreover, petitioners continued to make payments for months after the alleged intimidation, without questioning the promissory note or seeking protection. Ycong's own testimony admitted to making payments to avoid embarrassment, suggesting an acknowledgment of the obligation. The Court also noted that even if intimidation vitiated consent, the contract would only be voidable, not void, and required annulment by a proper court action. The Court also found it unlikely for someone in Ycong's position (a department manager) to be easily intimidated by the alleged actions of Moller, who was also a relative and neighbor. There is no information in the provided text regarding whether the petitioners had fully paid their outstanding loan obligations. Therefore, no ratio decidendi can be provided for this issue.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an appeal and cannot be used to correct errors of judgment, but only errors of jurisdiction or grave abuse of discretion. Factual issues are generally beyond the scope of certiorari.